ECOA New Appraisal Rule Apply to Home Builders?

Answered by:

Randy Carey

Jim Bedsole

Question:

Does the new appraisal rule under the ECOA apply to Home Builders?

Answer:

by Randy Carey: Yes - Regulation B applies to all credit, not just consumer.

Answer:

by Jim Bedsole: But there is an interesting term used in the definition of "consummation" in 1002.14(b)(1) - namely the term "consumer." I don't know that you could stretch it far enough to allow for not providing appraisals to business applicants for first-lien dwelling secured credit, but it is an interesting choice of words.